On 22nd November 2024, OxPCF presented at the Scrutiny Committee regarding the development of Oxfordshire County Council’s EOTAS (Education Other Than at School) Policy and Guidance. This was a critical moment to advocate for the voices of parent carers, children, and young people who rely on EOTAS.
Below, we share the speech delivered at the meeting, along with two key appendices: a timeline of events outlining the policy’s development and an email summarising the feedback and concerns we raised during the review process.
We hope sharing our speech and supporting materials helps families understand our role in advocating for their needs and holding the Local Authority accountable.
Speech for Scrutiny Committee: EOTAS Policy Development
Chair and Members of the Scrutiny Committee,
Thank you for the opportunity to speak today about the development of Oxfordshire County Council’s EOTAS (Education Other Than at School) Policy and Guidance.
This process is crucial for addressing the needs of children, young people, and their parent carers who rely on EOTAS. While this remains a small but vulnerable group, the number of those relying on EOTAS is increasing, driven in part by systemic failings within the Local Authority, as highlighted in the Ofsted inspection of July 2023.
As the formal representative of parent carers in Oxfordshire and a member of the Local Area Partnership, OxPCF works to ensure their voices are heard and reflected in this work. It is important to note that, as a Parent Carer Forum, our role is not to share personal opinions on the policy but to report the facts of what has occurred and the feedback we have gathered from families. It is important to note, co-production is a legal requirement under the 2014 Children and Families Act, forming a cornerstone of effective policymaking in SEND. The failure to co-produce this policy has caused significant and unnecessary distress to families, many of whom were initially assured that true co-production would take place.
We feel it is important to remind the Local Authority of its legal responsibilities to co-produce with families, particularly where this commitment has previously been expressed.
Between 2021 and 2024, we maintained this as a top priority. At the Better Together Event in 2023, Kate Bradley and Hayley Good publicly committed to producing an EOTAS policy and accompanying guidance. However, progress subsequently stalled. We were encouraged by Dr Kate Reynolds when she came into post that she reaffirmed the commitment to co-produce the policy and guidance with OxPCF and wider parental representatives and subsequently, we led on facilitating ongoing discussions with families.
By July 2024, the Local Authority decided the policy would be drafted internally. This decision frustrated EOTAS families, who had been promised a more collaborative process.
In September 2024, the EOTAS Listening Event marked a significant milestone. Co-facilitated by OxPCF, Oxfordshire County Council and supported by SENDIASS and the EOTAS/Personal Budget Facebook Support Group. It provided invaluable feedback from families and professionals. Key themes included the need for early intervention, personalised pathways, trauma-informed practices, and improved communication and transparency in decision-making. Families stressed that EOTAS should be recognised as a valid and structured educational pathway, not as a last resort.
Key concerns raised by OxPCF and families centre on the fact that the policy was drafted exclusively by the Local Authority. While it was made clear at the Listening Event that the policy itself would not be co-produced, this decision remains deeply disappointing. Families feel excluded from a process that directly affects their children and have expressed frustration that their lived experiences were not meaningfully integrated into the policy, which only adds to the sense of mistrust and exclusion they feel.
Initially, OxPCF was not granted access to review the draft policy. After persistent advocacy, only the chair and lead SG member were allowed to review draft 13, with just three working days during half-term to provide feedback. Collaborating with SENDIASS, we submitted detailed concerns to the Local Authority, the Head of the Council, and key stakeholders. We noted that much of the policy extended beyond legal requirements, incorporating guidance elements, yet failed to address the real needs of families and traumatised children. This raises significant concerns about whether the accompanying guidance can provide meaningful and effective impact.
Following the Listening Event, we are pleased that Oxfordshire County Council has taken a positive step by committing to the formation of working groups to develop the accompanying guidance. These groups will address critical themes, including personal budgets, safeguarding, coordination of packages, monitoring, and training.
This presents an opportunity to ensure the guidance reflects the lived experiences of families. We strongly urge the Local Authority to prioritise this work and involve their co-production team to facilitate effective and meaningful discussions that upholds the principles of genuine co-production and carefully consider all the concerns raised before finalising and implementing the policy to ensure it meets the needs of families and addresses their realities.
To rebuild trust and encourage collaboration, it is vital that the guidance development is delivered as promised. By taking this approach, Oxfordshire can set an example for other local authorities by creating a framework that is both inclusive and robust—balancing legal requirements with family-centred practices.
Looking ahead, OxPCF remains committed to advocating for all parent carers, including those impacted by the EOTAS policy.
Thank you for your time and attention. I hope we can work together to make this policy and guidance truly reflective of the needs and aspirations of our families.
Appendix 1: Timeline of Events – EOTAS Policy Development
2021
• Commitment made by Oxfordshire County Council to develop an EOTAS policy and guidance.
March 2022
• Dan Knowles, Parent Representative for Healthwatch on the Health, Education, and Social Care (HESC) committee, sought information about how EOTAS was being used at a multi-agency level.
June 2022
• Discussions between Kate Bradley (Head of SEND), Deborah Bell, and Cathy Clarke focused on the direction of the EOTAS policy and guidance development.
1st July 2022
• OxPCF holds a meeting with EOTAS families to gather insights about their challenges and lived experiences.
• Summary of feedback shared with Kate Bradley (Head of SEND) and Hayley Good (Deputy Director of Education).
2023 (Better Together Event)
• Public commitment made by Kate Bradley and Hayley Good to co-produce an EOTAS policy and accompanying guidance.
January 2024
• Dr. Kate Reynolds (Interim Deputy Director of Education) reaffirms the commitment to co-produce the EOTAS policy and guidance with OxPCF and parental representatives.
July 2024
• Local Authority decides that the policy will be drafted internally, with only the accompanying guidance to be co-produced.
• Decision causes frustration among families due to unmet expectations of co-production.
5th September 2024
• EOTAS Listening Event co-facilitated by OxPCF and Oxfordshire County Council
• Families and professionals provide feedback, identifying key themes such as the importance of early intervention, personalised pathways, trauma-informed practices, and improved transparency.
October 2024
• OxPCF granted access to draft 13 of the policy following sustained advocacy.
• Given three working days during half-term to review the draft.
• OxPCF collaborates with SENDIASS to provide detailed feedback and raises formal concerns with the Local Authority, Head of the Council, and stakeholders in education and SEND.
November 2024
• Policy presented at the Scrutiny Committee. Local Authority commits to forming co-production working groups to develop the guidance, addressing themes such as personal budgets, safeguarding, coordination, monitoring, and training.
Appendix 2: Email to Local Authority and Cllrs Highlighting Feedback and Concerns on the EOTAS Policy
Thank you for sharing the draft EOTAS policy with us for review. Firstly, I apologise for not sending this sooner but as it is half term, the forum is not meant to be working, and I have had to look at this while balancing the care needs of my family.
We appreciate the work that has gone into developing this document and understand the intention to outline the legal framework for EOTAS. We are aware you will be meeting Wendy on Monday to further review the policy; however, we felt it important to share our concerns formally, as we believe they may provide helpful insights for future revisions.
Clarity for Existing EOTAS Families
The policy currently reads as though EOTAS is a new or first-time option, which may create confusion for families already using this provision. We recommend clarifying that the policy is applicable to both new and existing EOTAS cases to avoid misunderstandings.
Appropriateness of Placements (Point 20)
Point 20 states that EOTAS will not be considered if any setting can meet a child’s needs. This wording could result in placements that meet only the minimum criteria, rather than providing a setting that is truly appropriate for the child. We suggest rephrasing this point to emphasise that placements should be appropriate to the child’s individual educational, social, and emotional needs.
Balanced Approach on Return to School
The policy emphasises reintegrating children back into school “at the earliest opportunity.” While this may be appropriate in many cases, it is important to recognise that some children may never be suited to a school environment. We suggest a balanced approach, affirming EOTAS as a valid, long-term option on a case-by-case basis.
Person-Centred, Flexible Provision
EOTAS is designed to meet the needs of children with complex, often fluctuating needs. The policy’s focus on “adequate” support could be strengthened by recognising the tailored, high-quality provision that many EOTAS cases require, thus providing an assurance of flexibility to meet children’s changing needs.
Transport and Financial Implications for Families
It would be helpful for the policy to state that families with children on EOTAS should not bear transport costs that would otherwise be covered if the child were in school. We recommend this be explicitly stated to reduce any additional financial strain on families.
Safeguarding Trust with EOTAS Families
Families using EOTAS place considerable trust in OCC’s commitment to their children’s well-being. Emphasising reintegration as a primary goal could inadvertently undermine this trust, particularly where EOTAS is still the most suitable provision. Stating that EOTAS remains a viable option when a school setting is unsuitable could help maintain confidence.
Accurate EHCPs
EOTAS decisions rely on up-to-date EHCPs that accurately reflect the child’s current needs. Acknowledging the potential impact of capacity issues within the SEND Casework team could provide transparency around decision-making constraints.
Complex Needs and Trauma
The policy could benefit from recognising the complex needs and trauma histories of children who rely on EOTAS. These families often view EOTAS as a necessary response rather than a “choice,” and it is important that the policy reflects this perspective.
Personal Budget/Funding
The purpose of a policy is to outline lawful practice and clear expectations. Therefore, we question whether running costs should impact the size of a personal budget, as this could inadvertently limit provision.
Implications and Responsibilities for Families
Supporting a child on EOTAS often requires parents to make significant sacrifices, including career changes. Recognising this impact could help strengthen the policy’s acknowledgment of family commitment.
Guidance and Security for Families
The policy might benefit from providing an additional point for existing EOTAS families to alleviate any anxiety around potential changes or loss of support.
Alignment with OCC’s Priorities
The policy’s focus on reintegration and minimal provision may not align with OCC’s priority of enhancing support for SEND children and families, and we recommend revisiting these elements to better reflect these commitments.
OxPCF’s Position
While OxPCF did not contribute to this draft, we believe the concerns outlined above reflect the perspectives of families in our community. We also ask that OxPCF not be directly referenced in connection with this policy, except to note that it was shared with us and that we have formally raised concerns about its potential impact on these vulnerable families.
We hope these points help refine the policy, ensuring it aligns not only with legal requirements but also with the needs and lived experiences of families relying on EOTAS.
To reiterate, we do appreciate the work that has gone into developing this policy and understand that balancing these complex needs is not an easy task. Thank you for considering our feedback and for your commitment to supporting children and families in Oxfordshire.
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